No section 14A disallowance if there is no exempt income in that year

DCIT Vs JSW Limited (ITAT Mumbai) The issue under consideration is whether A.O. is correct in restricting the disallowance under section 14A of the Income Tax Act, 1961, without appreciating the fact that the appellant company has not earned any tax-exempt income during the relevant assessment year? As per Section 14A of the Act, the purposes of computing the total income under Chapter, no deduction shall be allowed in respect of expenditure incurred by the assessee in relation to income which does not form part of the total income under the Act. Hence, what Section 14A provides is that if the...